The NY/NJ Baykeeper, Raritan Riverkeeper, American Littoral Society and COA supported comments prepared by the Rutgers Environmental Law Clinic on the draft New Jersey Pollutant Discharge Elimination System (NJPDES) Permit No. NJ0020141 for the Middlesex County Utility Authority (MCUA).  This permit comes up for renewal every five years and many permit conditions had not been updated for several permitting cycles.  There were some significant improvements in monitoring and limitation requirements but there were still problems with Enterococcus and Fecal Coliform limits, compliance and maintenance schedules, and the use of 14-year-old data to calculate some effluent limitation.  COA also continues to push MCUA to consider effluent reuse, treatment alternatives, and improved facility operations to reduce its impacts to the receiving water.